Emlak Konut

Values and Policies Disclosure Policy



A. Purpose and Scope:

Emlak Konut, with its “Disclosure Policy” and its past performance, as well as its plans and expectations for the future, as well as its strategy, target and vision, are in line with the provisions of the Capital Markets Legislation, Turkish Commercial Code, Borsa Istanbul Legislation and other relevant legislation. In accordance with the regulations, it provides timely, complete, accurate and effective information.

The disclosure policy covers all kinds of information, documents, electronic records and data, which are legally safe to be disclosed, regarding activities that do not have the characteristics of "Inside Information" and "Trade Secret" known to the members of the Board of Directors, senior managers and employees.

B. Public Disclosure Methods and Tools:

Emlak Konut uses the following methods and tools for its information policy within the framework of the period and principles specified for the periodic tables and reports specified in Articles 38 and 39 of the Communiqué on Principles Regarding Real Estate Investment Trusts numbered III-48.1.

      - Special case explanations,

      - Financial Statements and Footnotes, Independent Audit Report periodically submitted to Borsa Istanbul,

      - Quarterly and annual activity reports,

      - Corporate website (http://www.emlakkonut.com.tr),

      - Investor and Analyst Meetings,

      - Press releases and meetings,

Emlak Konut website access is provided at www.emlakkont.com.tr/.

The final version of Emlak Konut's articles of association, periodic financial statements and reports, prospectuses, public offering circulars and general assembly meeting agendas are available on the website.

The website will be constantly updated in order to reflect the latest status of the partnership and management structure. The Company will promptly respond to any information request received via the website.

The bulletins to be prepared by Emlak Konut in order to inform the public and/or within the scope of Emlak Konut's corporate communication activity, are prepared by Emlak Konut's Press Consultancy, with support in matters requiring expertise.

      1. Informing the Press:

       Emlak Konut organizes meetings and prepares press releases, adhering to the content of material disclosures, in order to inform them on issues that directly concern its activities, such as its ongoing projects, medium and long-term strategies. The principle of equality is respected among the members of the press who will be invited to the meetings.

      2. Principles of Following the News and Rumors About Emlak Konut in the Press and Media Organs or on the Internet Sites and Making Related Disclosures:

      Emlak Konut follows the news and rumors in national or international press-media organs or other communication channels according to the press monitoring procedure, and in case of presence of news or rumors with a different content than the information announced to the public for the first time or previously announced to the public; It evaluates whether these affect the value and price of the Company's shares or the investment decisions of the investors and, when deemed necessary, makes a public statement within the framework of the principles determined in the capital market legislation.

      Emlak Konut does not give any opinion on market rumors and speculations in principle. However, within the provisions of the Capital Markets Legislation, T.R. If a verification request is received from the Prime Ministry Capital Markets Board (CMB) and/or Borsa Istanbul, or if the management decides that an answer is necessary and more appropriate, an explanation is made for such unfounded news.

      3. Principles of Access to Presentations and Reports Explained at Investor Information, Investor Information Meetings or Press Conferences:

      Issues related to informing investors and analysts are handled by Emlak Konut's Investor Relations Department. Meeting requests from real or legal persons are evaluated and if the application reaches 10 people a week, a meeting date is determined and notified to the said requesters. Presentations and/or explanatory notes made at such meetings are published on the Emlak Konut website after the presentation, teleconference and speech. Emlak Konut officials may attend national and international conferences or meetings from time to time in order to share information with investors and analysts, and the presentations used in these meetings are also published on the Emlak Konut website. Questions directed by phone or e-mail are answered within 10 working days at the latest.

C. Inside Information and Measures Taken to Ensure Confidentiality of Inside Information until Public Disclosure:

In case of use in trading of capital market instruments, the inside information is related to a concrete event that may affect the value and price of the capital market instruments issued by Emlak Konut, or to the situations that a rational investor may consider meaningful while making an investment decision, and that has not yet been disclosed to the public. Information that may provide an advantage over other unaware investors and that, if disclosed to the public, may have an impact on the value of the said capital market instrument or on the investment decisions of investors.

Other parties in communication with Emlak Konut employees who have inside information will be informed that they are obliged to protect the confidentiality of this information during the formation of the material event and the process from the occurrence of the material event to its disclosure in Borsa Istanbul. Those working on behalf of Emlak Konut will not share any information that has not yet been disclosed to the public and that can be considered as a special case with third parties under any circumstances. In case it is determined that insider information has been disclosed to third parties unintentionally by these persons, when it is concluded that the confidentiality of the information cannot be ensured within the scope of the Capital Market regulations, Emlak Konut will immediately make a material event disclosure.

Emlak Konut prepares a list of real or legal persons acting on or on behalf of Emlak Konut, persons working under them by employment contract or otherwise and having access to insider information, within the framework of the CMB's “Special Circumstances Communiqué” numbered II-15.1. The process of preparing and updating the list is carried out by sending the persons who have access to Emlak Konut's Administrative Affairs and Human Resources Directorate by the relevant units.

The list of those who have access to inside information will be kept up-to-date by Emlak Konut in accordance with the changing scope of projects and subjects. The said list will be submitted to the relevant official institutions and organizations upon request. Emlak Konut provides written information on the protection of insider information to the persons on the list.

Emlak Konut may postpone the disclosure of inside information in accordance with the provisions of the CMB's "Special Circumstances Communiqué" numbered II-15.1 in order to prevent damage to its legal rights and interests.

D. Persons Authorized to Communicate with Shareholders and Make Public Disclosures:

Evaluating whether any information request regarding Emlak Konut is a trade secret and whether it can affect investment decisions and the value of capital market instruments within the framework of the CMB's "Special Cases Communiqué" numbered II-15.1;

      - Chairman and members of the Board of Directors,

      - General Manager,

      - Investor Relations Department,

will be answered either orally or in writing. Other employees other than these persons are not authorized to answer questions. Emlak Konut employees direct their questions to the Investor Relations Department.

E. Authority and Responsibility:

The Disclosure Policy will be established by the Emlak Konut Board of Directors with the decision of the Board of Directors, and the monitoring, monitoring and development of the Policy is under the authority and responsibility of the Board of Directors.

Changes to the Disclosure Policy are taken by the decision of the Board of Directors.

These policy provisions are executed by the Investor Relations Department.

F. Principles Used in Determining Persons with Administrative Responsibility:

Persons with Administrative Responsibility are the members of the board of directors who, although they are not members of the board of directors, have direct or indirect access to inside information on a regular basis and are authorized to make administrative decisions that affect the future development and commercial objectives of the company. Emlak Konut has determined the Persons with Administrative Responsibility as Board Members and Emlak Konut Senior Management.

G. Principles Regarding Disclosure of Forward-Looking Evaluations:

Evaluations of the company's plans and forecasts for the future, which are in the nature of inside information, may be disclosed to the public by persons authorized to make a public disclosure within the framework of the principles set forth in the capital market legislation. Forward-looking assessments are based on reasonable assumptions and estimates, and changes may be made in these forward-looking assessments in case of deviations due to unforeseen risks and developments. Due to risks, uncertainties and other factors, there may be differences between the actual results and the expected results in future evaluations. Differences in the aforementioned situation are disclosed to the investors within a reasonable time period.

Forward-looking evaluations can be made by making use of press releases, press conferences and/or press releases, national and international conferences or meetings, or other communication means, in addition to the statements to be made within the framework of the principles in the capital market legislation.